People v. Uriostegui
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The case revolves around Israel Marcial Uriostegui, who was convicted of first-degree residential burglary by a jury. Uriostegui appealed the judgment, arguing that the trial court erred in denying his objection under section 231.7 of the Code of Civil Procedure. This section aims to prevent the improper removal of jurors based on their actual or perceived race, ethnicity, gender, or membership in another protected group. Uriostegui's objection was based on the prosecutor's peremptory challenge against a prospective juror, T.N., who appeared to be Hispanic.
Previously, the trial court had asked T.N. for basic information during voir dire. T.N. disclosed her employment at Taco Bell, her current unemployment due to an injury, and her lack of prior jury service. She also revealed that two of her family members had been convicted of a crime, but she was not close to them. When the prosecutor exercised a peremptory challenge against T.N., Uriostegui's counsel objected, arguing that the basis for excusing T.N. was presumptively invalid under section 231.7. The prosecutor justified the challenge by citing T.N.'s "lack of life experience," her unemployment, and her demeanor. The trial court denied Uriostegui's objection, finding no substantial likelihood that T.N.'s perceived membership in a protected class was a factor in the peremptory challenge.
In the Court of Appeal of the State of California Second Appellate District, Uriostegui contended that the trial court erred in denying his objection under section 231.7. The court agreed with Uriostegui, stating that the prosecutor's reasons for excusing T.N. were presumptively invalid under section 231.7. The court found that the prosecutor's reasons and the trial court's findings did not overcome the presumption of invalidity. The court concluded that the trial court erred in denying Uriostegui's objection under section 231.7. As a result, the judgment was reversed, and the case was remanded for a new trial.
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